Village of Euclid v. Ambler Realty Co.

United States Supreme Court272 U.S. 365 (1926)

Facts

Ambler Realty Co. (Ambler) (plaintiff) owned land in the Village of Euclid (Euclid) (defendant). Euclid is a largely residential suburb of Cleveland, Ohio. In 1922, Euclid enacted comprehensive zoning ordinances and created a board of zoning appeals charged with enforcement. The regulations created different districts based on the class of use, including purely residential, mixed use, commercial, and industrial. As a result of the ordinance, Ambler’s land was partitioned in terms of the types of uses that were permissible on it. Most notably, portions of Amber’s land were zoned in such a way as to prohibit the development of industry. Ambler brought suit against Euclid, alleging that the zoning ordinance violated the Fourteenth Amendment of the United States Constitution, as well as the Ohio Constitution, by depriving Ambler of liberty and property without due process. Specifically, Ambler argued that the ordinance significantly reduced the land’s value and deterred potential buyers. Euclid moved to dismiss on the ground that the zoning regulations had not yet been enforced against Ambler, because Ambler had not applied for any building permits. The motion was denied. The district court held that the ordinance was unconstitutional and enjoined its enforcement. Euclid appealed to the United States Supreme Court.